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Who? According to the DHHS Monitoring of Programs policy, each division that has financial assistance arrangements with subrecipients shall develop and maintain a subrecipient monitoring plan - DPH programs are responsible for developing and maintaining their own plan(s).
What is a Subrecipient Monitoring Plan? The Division of Public Health Subrecipient Monitoring Plan (provided below at Item C) is the basis for monitoring program and fiscal compliance with state and federal requirements. The primary objective of the monitoring plan(s) developed by programs is to ensure that subrecipients are complying with applicable rules and regulations and that the program(s) are accomplishing their intended purpose(s).
How? The Division's Subrecipient Monitoring Plan (Item C) details how DPH plans to monitor its programs.
When? How often should monitoring and reporting occur? The frequency and intensity of monitoring techniques applied to a given subrecipient will be directly proportional to the level of risk assigned. The amount of financial and programmatic monitoring, and the techniques used, will vary based upon the DPH risk-based system outlined in Section "VI. Risk Assessment" of the Division's Subrecipient Monitoring Plan.
Why? To comply on federal, state, and departmental levels - further regulatory background information is available in the Division's Subrecipient Monitoring Plan. Links to specific regulations are available under "Resources" (Item F).
Pass-through Entities: State agencies in receipt of federal or state funds that are sub-awarded to private or other state agencies for provision of services in support of a specific program or project. Pass-through entities are responsible for monitoring grants to provide reasonable assurance that:
Federal and state grant funds are expended in ways that meet provisions of pertinent statutes, regulations, agency administrative requirements, relevant OMB circulars, and the terms of the award notice.
Adequate progress is being made toward achieving the sub-award project’s goals and objectives (as defined in award application packets).
Subrecipient Agency: An agency or organization that receives federal or state awards from the Division of Public Health. These agencies are usually non-profit or governmental agencies or organizations, but in some instances may be for-profit entities. (State agencies routinely monitored by the Office of the State Auditor are not necessarily included in this definition, but consideration should be based on prior experience with the state agency in question.
Federal or State Awards: Financial assistance and cost-reimbursement contracts that non-federal and non-state entities receive directly from federal or state awarding agencies or indirectly from pass-through entities. (The payments received for goods or services provided as a vendor are not considered federal or state awards.)
Monitoring: Activities that are part of a continuous improvement strategy designed to assure that public funds are allocated and spent in a manner that maximizes the level of program benefits to the public and to other stakeholders (e.g. granting agency, DPH, and the subrecipient). Monitoring is incorporated into all aspects of the post-award process.
Cost Disallowance: A charge to a grant that the division determines to be unallowable, according to the applicable cost principles (OMB Circular A-122 for non-profit organizations, A-21 for educational institutions, and A-87 for state, local, and Indian tribal governments) or other award terms and conditions. The general rule of thumb for any costs to be considered proper is that they must be allowable, allocable, necessary, reasonable, and treated consistently.
Temporarily Withholding Funds: Action taken by the division, after appropriate administrative procedures have been followed, which delays a subrecipient’s ability to access its grant funds until it takes corrective action required by the pass-through entity.
Suspension: Action by the division that temporarily suspends financial assistance under the award, pending corrective action by the subrecipient or a pass-through entity’s decision to terminate the award.
Termination: Permanent cancellation of the subrecipient’s authority to obligate all or part of the funds awarded to it. Awards may be terminated under the following conditions as outlined in OMB Circular A-110:
By the division, if the subrecipient materially fails to comply with the terms and conditions of the award;
By the division, with the consent of the subrecipient; or
By the subrecipient, upon sending written notification to the agency stating the reasons for the termination.
Voiding of a Grant: Determining that the award was obtained fraudulently, or was otherwise illegal or invalid from inception. Voiding, in effect, is a decision that the grant never legally existed. Such determinations are rare, but possible.
Debarment and Suspension: Government-wide actions based on Executive Order 12549 which exclude a person or organization from participating in grants or other assistance awards. Suspensions are temporary actions, not to exceed 18 months, generally leading to debarment, implemented only when immediate action is needed to protect the government’s interest. Debarment generally lasts three years.
All Programs of DPH are required to have a Records Retention & Disposition Schedule.
What is a Records Retention and Disposition Schedule?
This document is a tool for employees in an office to use to manage the records in their office. Lists records commonly found in an office and gives an assessment of value by indicating when records may be destroyed.
Why do I have to have a schedule?
It is the law. According to G.S. 121-5 and G.S. 123-3, you may only destroy public records with the consent of the Department of Cultural Resources. DCR can only give consent if there is a schedule.
How ?
If you do not have a Records Retention & Disposition Schedule, you must develop one. Complete the “Public Records Series Listing” form and return to the State Records Center.
When?
Schedules should be reviewed annually and inventory records. If the schedule needs updating (i.e., records no longer in use, disposition changes), complete the “Public Records Series Listing” form and return to the State Records Center.
*Note: "Last Modified" or "Last Published" dates apply only to documents maintained by the Division of Public Health and not linked on an external web site.
